The  issued Industry Circular 2020–3 on May 8, 2020 which clarifies the applicability of the trade practice provisions of the Federal Alcohol Administration (FAA) Act and TTB regulations during the COVID-19 public health emergency.  The guidance is in effect only from March 1, 2020 through September 30, 2020.
Continue Reading TTB Relaxes Certain Trade Practice Rules During COVID-19

As with all businesses, franchise systems are dealing with challenges from COVID-19 that are new and unexpected. Franchisors and franchisees will have to work together, communicate and support each other to overcome these challenges and allow their brands to survive and thrive in the future. Below are some key considerations for both franchisors and franchisees as they move forward into uncharted territory.

Continue Reading COVID-19 Considerations for Franchise Systems

COVID-19 (Coronavirus) has drastically impacted all facets of everyday life, including the way in which alcohol sales can be conducted. Though most jurisdictions have banned dine-in customers at restaurants, bars and tap rooms, many have permitted on-premise licensees to temporarily sell to consumers through delivery, curb-side pickup, or off-premise sales. It is imperative to contact

On March 17, 2020, the U.S. Food and Drug Administration (FDA) issued guidance to food manufacturers and importers in response to the COVID-19 pandemic.  In the guidance, FDA stated it will temporarily not enforce supplier verification onsite audit requirements for receiving facilities and importers under the Food Safety Modernization Act (FSMA) so long as other supplier verification methods are used instead.

Continue Reading FDA Issues Temporary Policy for Food Manufacturers and Importers in Light of COVID-19 Outbreak

Companies directly and indirectly regulated by the U.S. Food and Drug Administration (FDA) face specific challenges separate from other businesses in dealing with the recent outbreak of coronavirus disease 2019 (COVID-19).  At the time of this writing, FDA has not offered specific recommendations on measures that regulated industries should take.  However, good manufacturing practice (“GMP”) requirements and the Federal Food, Drug and Cosmetic Act (“FDCA”) impose obligations on regulated industry to monitor and control employee health and sanitation practices as they relate to product quality and safety.  Beyond the risk of state and federal enforcement, there are reputational risks associated with inadequate management of COVID-19.

Continue Reading Coronavirus in FDA-Regulated Industries